EFTA01082182.pdf

LANKLER SIFFERT & WOHL LLP ATTORNEYS AT LAW 330° FLOOR TELEPHONE 500 FIFTH AVENUE TELEFAX a Ncw YORK, N. Y. 101 10-3398 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 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 of misconduct which tend to discredit the witness' character and show him or her to be unworthy 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. "I'm not In a February 25, 2011 article in the New York Post, Mr. Epstein was quoted as saying, who a sexual predator, I'm an 'offender.' It's the difference between a murderer and a person 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. Ref. No.: 1425006537 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. THIRD-PARTY RESPONDENTS' FIRST REOUEST FOR PRODUCTION D.B. Zwim Partners, LLC, D.B. Zwim & Co, L.P., DBZ GP, LLC, Zwim Holdings, d LLC, and Daniel Zwim (together "Third-Party Respondents"), by and through undersigne documents counsel, hereby request that Financial Trust Co, Inc. and Jeepers, Inc. produce the 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, their behalf. parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on 2. "Zwim Entities" means Daniel Zwim, D.B. Zwim Partners, LLC, D.B. Zwim & members, employees, Co, L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their representatives, agents, predecessors, and anyone else acting on their behalf. 3. "Fund" means D.B. Zwim Special Opportunities Fund n/k/a Fortress Value Fund and includes its Recovery Fund I LLC and f/k/a Highbridge/Zwim Special Opportunities 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, n internal or external memoranda, letters, drafts, non-identical copies, notes including handwritte or 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, text messages, tape or electronic recordings, videotapes, diaries, sketches or designs, banking appointment or telephone records, newspaper or magazine articles, press releases, computer records and notices, and information of whatever kind stored on computers, including 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 and use of the singular form of any word includes the plural and vice versa; "any" includes both encompasses the words "each" and "all"; terms referring to or using one gender include the past genders; terms used in the present tense include terms in the past tense and terms in 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 LANKLER SIFFERT & WOHL LLP By: t eS Alan Levine apm By: John S. Siffert William O'Brien Daniel E. Reynolds Arastu K. Chaudhury Andrew S. Lee 1114 Avenue of the Americas 500 Fifth Avenue New York New York 10036 New York. New York 101 10 Attorneys for Third-Party Respondents D. B. Attorneys for Third-Party Respondent Zwirn Partners, LLC (n/k/a Irvington Daniel Zwirn 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 EFTA01082192 Exhibit B EFTA01082193  r p i ast Up0ast roe taw 8 2011 05 Mem Lindsay LOW - Carlos Bertrar - Csare Sneer jern.tet Ar.stOr Lady Gaga Page Six fl Sports fol Entertainment e Voodoo shock r Tiki to play The odd couple • lc... SS •o-w. Peva Gossip Celeb Photos PopWrap Teams High Schools TV Movies Events Travel Scores Hems NYC Local Business Opinion Columnists Politics Metro US News World News Real Estate Weird But True Crime Lottery Story Billionaire Jeffrey Epstein: I'm a sex offender, not a predator a r AMPLH SU:haH..12/54y a:4 V. 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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. NEW YORK POST ;$ a 'scooped vodernark of NY P tIOICIng. Inc NYPOST CAM • NYPOSTOKINE COM ran* er/ORK->CS- CCM we trocromaas of MVP rice:imps inc Copyrwahl 2011 !Op poking* IM Ar nghls rolineed PraCy I TOM.. a. UV. http://www.nypost.com/f/print/news/local/manhattan/bizman_sex_rap_looms_x672DpmZE.. 3/7/201 1 EFTA01082197 Exhibit D EFTA01082198 Schoolgirls Net "massage" messages at Florida home of Nnert billionaire Jeffrey Epstein... Page 2 of 4 39' 'Ian • Ibliere, Lope Meymota City • illetn.••• franc a. 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Page 1 of 2 Prince Andrew tours Manhattan with billionaire sex offender Jeffrey Epstein By CATHY BURKE unsve n )/ AM rwn.. 21 AllI 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 -setting prince - dubbed back home as "His Buffoon Highness." — jokingly compared At the party. Page Six reported. the jet 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. NEW YORK POST • II TOgitlefe0 inicierna co NYP Haply. Inc NYPOST COM NYPOSTONTOKE COM re NEWTORKPOST COM ite vwmrt. Cl NYP moons. inc hup://www.nypost.com/f/print/news/localAnanhattan/perv_mogul_gets_royal_treatment_Q... 3/7/2011 EFTA01082201 Exhibit F EFTA01082202 Lawsuit documents link Jettrey Epstein to modeling agency owner Jean Luc Brunel Page 1 of 2 PalmBeachDailyNews.com •".,•• ""•Lawsuit documents link Print this page Close Jeffrey Epstein to modeling agency owner Jean Luc Brunel By MICHELE DARGAN DAILY NEWS STAFF WRITER Updated: 8:16 p.m. Friday, Oct. 15. 2010 Posted 8:0O p.m. Friday, Oct 15. 2010 New court filings in a civil case filed by billionaire sex offender Jeffrey Epstein link Epstein and Jean Luc Brunel, owner of modeling agency MC2. The documents say MC2 employees told attorney Brad Edwards that Epstein's condos at 301 E. 66th St. in New York City were used to house young models. Edwards, who has sued Epstein on behalf of several women claiming to be victims of sex abuse by Epstein, was told MC2 brought underage girls in from all over the world, promising them modeling contracts 'Epstein and Brunel would then obtain a visa for these girls, then would charge the underage girls rent." the documents say. Through the investigation of his lawsuits against Epstein. Edwards learned Brunel "runs the modeling agency MC2. a company for which Epstein provides financial support," the documents say They also allege Epstein tried to thwart Edwards from taking depositions of Brunel. Epstein's companion Guislaine Maxwell, and other high-profile names such as President Bill Clinton Details are listed