EFTA00294815Set 9
2002-10-2832p9,752w
Between:
FINANCIAL TRUST COMPANY, INC., and
THE C.O.U.Q. FOUNDATION, INC.,
FINRA No. 09-00979
Claimants,
v.
STATEMENT OF ANSWER
THE BEAR STEARNS COMPANIES, INC.,
BEAR, STEARNS & CO. INC., BEAR
STEARNS ... investors sock to recover losses they suffered as a
result of their own speculation. Claimants Financial Trust Company, Inc. ("FTC") and The
C.O.U.Q. Foundation, Inc. ("COUQ") are entities that billionaire ... overwhelm the
Funds' liquid resources and lead to losses.
Epstein executed documents representing that Claimants completely understood all of these
risks.
For over three years, FTC and COUQ enjoyed positive
https://www.justice.gov/epstein/files/DataSet%209/EFTA00294815.pdf
EFTA01130666Set 9
27p6,225w
Financial Trust Company, Inc. ("FTC"), The C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey
Epstein (together, "Claimants") and (ii) The Bear Stearns Companies Inc. (n/k/a The Bear
Stearns Companies LLC), Bear, Stearns ... n/k/a J.P. Morgan Securities LLC) and Bear
Stearns Asset Management Inc. (together, "Respondents").
WHEREAS Claimants made certain investments, directly or indirectly, in (a) one
or more of Bear Steams High ... Bear
Stearns Companies Inc. ("BSCI Securities"); and
WHEREAS there exist certain disputes between Claimants and Respondents
arising from losses that Claimants allegedly suffered as a result of the investments described
https://www.justice.gov/epstein/files/DataSet%209/EFTA01130666.pdf
EFTA00613999Set 9
2011-07-2125p7,382w
Reference No. 1425006537: In the Matter of the Arbitration Between
Fortress VRF I LLC, Claimants, and Jeepers, Inc., Respondent
Dear Judge Carpinello:
Attached you should find: (1) a hard copy ... Claimants' Memorandum of
Law in Opposition to Financial Trust Company, Inc.'s and Jeepers, Inc.'s Motion In
Limine "To Exclude Extrinsic Evidence"; (2) a binder of exhibits cited ... FORTRESS Arbitrator: Hon. Anthony J. Carpinello (Ret.)
VALUE RECOVERY FUND I LLC,
Claimants
v.
JEEPERS, INC.,
Respondent CLAIMANTS' MEMORANDUM OF LAW
IN OPPOSITION TO FINANCIAL TRUST
and
COMPANY
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613999.pdf
EFTA01222686Set 9
4p1,686w
Name (as shown on your income tax ream) Taxpayer Identification number
Caution: Claimant has the name and address of the person who sold the fuel to the claimant ... lines lc and 2b (type of use 13 or 14), 3d, 4c, and 5, claimant has not waived the right to make the claim.
For claims on lines ... type of use 13 or 14), claimant certifies that a certificate has not been provided to the
credit card issuer.
1 Nontaxable Use of Gasoline Note: CRN Is credit reference
https://www.justice.gov/epstein/files/DataSet%209/EFTA01222686.pdf
EFTA00727326Set 9
2010-12-039p1,789w
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 ... Counter-Claimants and
Third-Party Claimants,
v.
FORTRESS VALUE RECOVERY FUND I LLC,
Counter-Respondents,
and
D.B. ZWIRN PARTNERS, LLC,
D.B. ZWIRN & CO, L.P.,
DBZ GP, LLC, ZWIRN HOLDINGS ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00727326.pdf
EFTA00729270Set 9
8p1,968w
MATTER OF
FORTRESS VRF I LLC and FORTRESS
VALUE RECOVERY FUND I LLC,
Claimants
v.
JEEPERS, INC.,
Respondent Case No. 1425006537
and
FINANCIAL TRUST COMPANY, INC. and
JEEPERS, INC.,
Counterclaimants ... Third-Party Claimants
v.
Arbitrator: Hon. Anthony J. Carpinello
D.B. ZWIRN SPECIAL OPPORTUNITIES
FUND, L.P. k/n/a FORTRESS VALUE
RECOVERY FUND I LLC,
Counter-Respondent
and
D.B. ZWIRN PARTNERS ... documents, if any, that may exist.
4. All documents and communications concerning Third-Party Claimants'
investments in the Fund.
Response: Respondents object because this request is overly broad, vague
https://www.justice.gov/epstein/files/DataSet%209/EFTA00729270.pdf
EFTA01093063Set 9
12p2,501w
MATTER OF
FORTRESS VRF I LLC and FORTRESS
VALUE RECOVERY FUND I LLC,
Claimants
v.
Reference No. 1425006537
JEEPERS, INC.,
Respondent
and
FINANCIAL TRUST COMPANY, INC.
and JEEPERS, INC.,
Counter ... Claimants and Third-Party
Claimants
v.
Arbitrator: Hon. Anthony J. Carpinello (Ret.)
FORTRESS VALUE RECOVERY FUND
I LLC,
Counter-Respondent
and
D.B. ZWIRN PARTNERS, LLC,
D.B. ZWIRN ... automated backup archiving practices.
8. Disclosures to Auditors/Investors. The Parties agree and acknowledge that
Claimants Fortress VRF I LLC and Fortress Value Recovery Fund I LP (together, "Claimants")
shall
https://www.justice.gov/epstein/files/DataSet%209/EFTA01093063.pdf
EFTA01128579Set 9
2011-06-073p1,264w
Jeepers. Inc., JAMS Ref. No. 1425006537
Dear Judge Carpinello:
On behalf of Claimants VRF I LLC and Fortress Value Recovery Fund I
LLC (together, "Claimants"), we write to respond ... native format without the redaction of the names of the Fund's other investors.
Claimants oppose the first request because they see no reason for treating Mr. Suan
differently than ... other hearing witness; as to the second request, Claimants have no
problem with providing the information at issue in native format, but do continue to
request that the names
https://www.justice.gov/epstein/files/DataSet%209/EFTA01128579.pdf
EFTA01107722Set 9
2010-05-217p1,324w
MATTER OF
FORTRESS VRF I LLC and FORTRESS
VALUE RECOVERY FUND I LLC,
Claimants
v.
JEEPERS, INC.,
Respondent Case No. 1425006537
and
FINANCIAL TRUST COMPANY, INC. and
JEEPERS, INC.,
Counterclaimants ... Third-Party Claimants
v.
Arbitrator: Hon. Anthony J. Carpinello
D.B. ZWIRN SPECIAL OPPORTUNITIES
FUND, L.P. k/n/a FORTRESS VALUE
RECOVERY FUND I LLC,
Counter-Respondent
and
D.B. ZWIRN PARTNERS ... mail: hsusmanasusmangodfrty.com
Attorneys for Respondent Counterclaimants and Third-Party Claimants
Financial Trust Company, Inc. and Jeepers, Inc.
EFTA01107723
JAMS ARBITRATION
IN THE MATTER OF
FORTRESS VRF I LLC and FORTRESS
https://www.justice.gov/epstein/files/DataSet%209/EFTA01107722.pdf
EFTA01147326Set 9
2003-04-1435p15,282w
disposition of such claim is
made within ninety (90) days of request therefor. The claimant in such enforcement action, if
successful in whole or in part, shall be entitled ... shall be entitled to raise as a defense to any such action that the claimant
has not met the standards of conduct that make it permissible under the California General ... Corporation Law for the corporation to indemnify the claimant for the amount claimed. Neither
the failure of the corporation (including its board of directors, independent legal counsel or its
shareholders
https://www.justice.gov/epstein/files/DataSet%209/EFTA01147326.pdf
EFTA01123523Set 9
2011-01-0314p3,014w
interplead. Joinder for
interpleader is proper even though:
(A) the claims of the several claimants, or the titles
on which their claims depend, lack a common origin
or are adverse ... plaintiff denies liability in whole or in part to
any or all of the claimants.
The purpose of interpleading a third party is to allow:
"a party who fears being ... Accordingly, interpleader
allows a stakeholder who "admits it is liable to one of the
claimants, but fears the prospect of multiple liability[,] . . . to file
suit, deposit the property with
https://www.justice.gov/epstein/files/DataSet%209/EFTA01123523.pdf
EFTA00078665Set 9
2019-11-141p593w
Biros will draft the program protocol and will
afford interested parties, including potential claimants and/or their legal representatives, an opportunity to provide
input on the protocol prior to its finalization ... program will be entirely voluntary and will not affect any rights the
claimant may have unless and until she accepts the compensation determination and signs a litigation release. All
claimants ... implement this important program, and are eager to
begin designing it so that claimants will have a forum where their suffering is acknowledged and their claims are
promptly and appropriately
https://www.justice.gov/epstein/files/DataSet%209/EFTA00078665.pdf