1. Jeffrey Epstein and Financial Trust Company, Inc. invested hundreds of millions of dollars with Highbridge as an investment manager with its many sub- advisors from 2001 to the present. 2. Daniel B. Zwirn had been one of those sub-advisors beginning in 2002 and, according to the Securities and Exchange Commission, remained a sub-advisor through at least 2007. 3. Mr. Epstein has had virtually no contact with Mr. Zwirn, except for a five minute face-to-face introduction and various telephone calls trying to resolve disputes. 4. Glenn Dubin negotiated and solicited each of Mr. Epstein's investments with the Zwirn fund, as well as the commissions and the other terms in respect thereof. For example, at Mr. Zwirn's request, Mr. Dubin requested that Mr. Epstein pay a 2% management fee to the Zwirn fund, rather than Mr. Epstein's offer of 1.3%. In addition, Mr. Dubin solicited Mr. Epstein, through Financial Trust Company, Inc., to invest an additional $20 Million with the Zwirn fund in January 2005 and negotiated a side letter with Mr. Epstein limiting Mr. Epstein's lock-up period to two years, as opposed to the three-year lock-up period the Zwirn fund was imposing on other investors. [JE, REMEMBER THERE WAS ALSO A ONE-YEAR PLUS LIQUIDITY OPTION --- SO WE CAN'T SAY "EVERYONE ELSE". ALSO, I BELIEVE THIS WOULD BE THE FIRST TIME THAT WE EVER CLAIMED THAT YOU NEGOTIATED THE SIDE LETTER WITH GLENN. ASSUMING THAT THIS OUTLINE IS DISCOVERABLE ... J. 5. At the same time, and without notifying Mr. Epstein, Highbridge had begun to withdraw its managed account with Mr. Zwirn at the direction of J.P. Morgan. Mr. Zwirn was liquidating the managed account and provided the motivation for fraudulently inducing Mr. Epstein to stay in the Zwirn fund, so that the Highbridge managed account would continue to be liquidated without impediment threatened by Mr. Epstein's demands for the withdrawal of his investment. In this regard, it is important to note that