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. Zwim 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. Zwim, 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 Zwim fund, rather than Mr. Epstein's offer of 1.3%. In addition, after the purchase of highbridge by JPM. Mr. Dubin solicited Mr. Epstein, through Financial Trust Company, Inc., to invest an additional $20 Million with the Zwim fund in dec 04. 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 Zwim fund was imposing on other investors. 5. IN early 05, Highbridge began to withdraw its managed account with Mr. Zwim at the direction of M. Morgan. In early oct 05 mr epstein was notified that there had been irregularities at the firm.. He immediately demanded a full withdrawal. Mr Dubin , as per his affidavit, and in conjunction with Dan Zwim, persuaded Mr Epstein to reduce the demand to 80 million dollars.. a written demand was sent on Nov 13. Unbeknowest to Mr Epstein at the time Mr. Zwim was focused on liquidating the managed account. THis provided the motivation for fraudulently inducing Mr. Epstein to stay in the Zwim fund, so that the Highbridge managed account would continue to be liquidated without impediment threatened by Mr. Epstein's demands for the withdr