EFTA01150049Set 9
2011-06-14272p47,421w
Suan what?
18 A. Chris Suan, S U A N, Vasan
19 Kesavan, and Perry Gruss at some point.
20 Q. And do you recall who
21 percentages of ownership ... companies
19 that we had at that time and thereafter.
20 Initially led by Perry Gruss, then a
21 combination of Perry Gruss and Harold
22 Kahn, and then ... managed. All of the non-investment people
19 of the firm reported first to Perry Gruss,
20 then to a combination of Perry Gruss and
21 Harry Kahn, and ultimately
https://www.justice.gov/epstein/files/DataSet%209/EFTA01150049.pdf
EFTA01104798Set 9
2004-10-0160p17,336w
knowledge of the improprieties, the law
firm hired to investigate concluded that Perry Gruss personally oversaw and approved of these
transactions. Mr. Gruss was both an officer (Chief Financial Officer ... underlying accounting problems, including for
example that the misconduct was not confined to Perry Gruss. Had FTC known any of these
facts, FTC would have demanded to withdraw $133 million ... problems at the
Fund, including that the problem was not simply confined to Perry Gruss.
FTC clearly relied on the Fund's failure to inform FTC of these facts
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104798.pdf
EFTA01105263Set 9
2004-10-0160p17,309w
knowledge of the improprieties, the law
firm hired to investigate concluded that Perry Gruss personally oversaw and approved of these
transactions. Mr. Gruss was both an officer (Chief Financial Officer ... underlying accounting problems, including for
example that the misconduct was not confined to Perry Gruss. Had FTC known any of these
facts, FTC would have demanded to withdraw $133 million ... problems at the
Fund, including that the problem was not simply confined to Perry Gruss.
FTC clearly relied on the Fund's failure to inform FTC of these facts
https://www.justice.gov/epstein/files/DataSet%209/EFTA01105263.pdf
EFTA00731279Set 9
2006-10-0447p12,057w
unexecuted Supplementary
Agreement among D.B. Zwim & Co., L.P., D.B. Zwim Partners, LLC and Perry Gruss (the
"Supplementary Agreement").
58. Deny the allegations of Paragraph 58, except admit that Gruss
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731279.pdf
EFTA00722309Set 9
2010-05-2120p4,025w
Fund's operations,
finances, or accounting prompted by or occurring after the departure of Perry Gruss from
involvement with the Fund or any of the Zwim Entities.
36. All witness ... Fund's operations, finances, or accounting.
37. All documents concerning the termination of Perry Gruss.
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13
EFTA00722321
Timestamp: 8/16/2010 5:38 PM CDT
38. All communications among Counterclaim Respondents ... documents concerning when Zwirn learned of the transactions that lead to the
termination of Perry Gruss.
40. All documents concerning the investigation by the Fund's counsel concerning the
transaction
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722309.pdf
ZWIRN HOLDINGS, LLC,
DANIEL ZWIRN, and
Third-Party Respondents
SUBPOENA DUCES TECUM
To: Perry Gruss
do Ethan Brecher, Esq.
Liddle & Robinson. LLP
10022
EFTA00599546
NOTICE IS HEREBY GIVEN that pursuant ... Zwim Partners, LLC, No. 09 Civ. 6441 (S.D.N.Y.).
3. "You" means Perry Gruss.
4. Rules of construction: "All" and "each" shall be construed as all and each ... ZWIRN HOLDINGS, LLC,
and DANIEL ZWIRN,
Third-Party Respondents.
SUBPOENA AD TESTIFICANDUM
To: Perry Gruss
c/o Ethan Brecher, Esq.
Liddle & Robinson, LLP
New York, NY 10022
EFTA00599550
NOTICE IS HEREBY
https://www.justice.gov/epstein/files/DataSet%209/EFTA00599546.pdf