Case File
efta-efta00721995DOJ Data Set 9OtherSUSMAN GODFREY L.L.P.
Date
Unknown
Source
DOJ Data Set 9
Reference
efta-efta00721995
Pages
2
Persons
0
Integrity
No Hash Available
Extracted Text (OCR)
Text extracted via OCR from the original document. May contain errors from the scanning process.
SUSMAN GODFREY L.L.P.
A REOI
LIMITED LiAaiun' •ARTNCRSHIP
5TH FLOOR
654
MADISON AVENUE
NEW YORK,
NEW Y
RK
10005-8404
FAX
SUITE 5100
1000 Loimiliam• 57nrer
Mauna+ Texas 77002-5006
STana -
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State 5100
001 Ma. U? to
Clau-as Ttxas 75202.3775
Sn 950
1991 "soma, Or Mt STAR[
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7-6020
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E-Mat
March 25, 2010
CONFIDENTIAL: FOR SETTLEMENT PURPOSES ONLY
Via Electronic Mall
Mr. Brad S. Karp
Paul Weiss
1285 Avenue of the Americas
New York, New York 10019
Re:
Fortress Investment Group LLC and Jeffrey Epstein
Sum 3800
I 20 J Maio A.4.1111L
SIGA^LE WaStIOCC•I 0619 i -3000
Dear Mr. Karp:
This letter sets out the basis and terms upon which Peter Briger, on
behalf of the Fortress Value Recovery Fund I LLC (f/k/a D.B. Zwirn Special
Opportunities Fund, L.P., the "Fund"), and Jeffrey Epstein (in his personal
capacity and in his capacity as President of Jeepers, Inc. and sole shareholder of
Financial Trust Co. ("Mr. Epstein")) will hold discussions regarding Mr.
Epstein's potential dispute with the Fund:
1.
The parties have agreed to hold discussions on March 26,
2010.
2.
The discussions will take place with the participation of
outside counsel to each party.
3.
The meeting will take place at the offices of Fortress
Investment Group, 1345 Avenue of the Americas.
EFTA00721995
March 25, 2010
Page 2
4.
The parties agree that the meeting, as well as any and all
communications between the parties, and any and all materials exchanged
between the parties, at or relating to the meeting are confidential and for
settlement purposes only. Nothing discussed or exchanged between the parties at
or relating to the meeting shall be used for any other purpose; provided however
this agreement shall not apply to information or material obtained from sources
other than the meeting.
5.
All of the discussions at or relating to the meetings
described above, and any information exchanged in connection with those
discussions and/or meetings, shall be subject to all of the protections available
under Delaware law, Rule 408 of the Federal Rules of Evidence and any other
applicable rules and/or privileges for settlement discussions and materials.
6.
Nothing discussed or exchanged between the parties at or
relating to the meeting or meetings shall waive any of the parties' rights or
remedies. The parties specifically reserve all of their rights and remedies.
If these terms are acceptable, please indicate your acceptance
below on behalf of your client Mr. Epstein and return a copy of this letter
agreement to me via email and Federal Express.
Counsel for Mr. Epstein
Agreed and Accepted:
Brad S. Karp
Counsel for the Fund
EFTA00721996
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