IN THE UNITED STATES DISTRICT COURT FOR THE UNITED STATES VIRGIN ISLANDS JEEPERS, INC., Case No.: Plaintiff, - against - D.B. ZWIRN PARTNERS, LW and DANIEL ZWIRN, Defendants. COMPLAINT Plaintiff Jeepers, Inc., for its Complaint against Defendants D.B. Zwirn Partners, LLC and Daniel Zwirn, alleges on personal knowledge with respect to itself and its own acts and upon information and belief as to all other matters, as follows: INTRODUCTION 1. Jeepers, Inc. ("Jeepers"),' a limited partner in the D. B. Zwim Special Opportunities Fund, L.P. (the "Fund"), brings this action to recover damages resulting from the fraudulent scheme perpetrated by the Fund's General Partner, D.B. Zwirn Partners, LLC ("D.B. Zwirn"). Over the course of nearly five years, Jeepers invested $80 million in the Fund, all of which D.B. Zwirn eagerly accepted. But when Jeepers sought to withdraw its money from the Fund D.B. Zwirn resorted to fraud and breach of fiduciary duty to prevent this withdrawal. 2. These misrepresentations and breaches of fiduciary duty were all part of Defendants' illicit scheme to conceal a massive accounting fraud at the Fund through which Defendants enriched themselves at the expense of Jeepers and the other limited partners. D.B. Zwirn falsely and repeatedly told Jeepers that there was "nothing wrong" at the Fund when, in Jeepers, Inc. is the assignee of all rights held by the Financial Trust Company, Inc. ("FTC") with respect to the Fund. K&E I2W-6503 EFTA00585800