Topics for Document Requests

Topics for Document Requests Accounting Irregularities 1. Report of Independent Review 2. Docs relating to Report of Independent Review 3. Docs produced, reviewed, created in connection with the internal investigation 4. Witness statements from investigation 5. Docs concerning the SEC, including does produced to the SEC and docs received from the SEC 6. SEC subpoenas 7. Testimony given to SEC 8. Docs and testimony given to any other agency or regulatory body 9. Docs concerning termination of CFO and CFO litigation 10. Other employee litigation Fortress 1. Due diligence re: Fund 2. Review, analysis of redemption claims and exposure 3. Docs concerning FTC claims 4. Indemnity Agreement w/ DZ 5. Joint Defense/Common Interest Agreement w/DZ 6. Information Sharing Agreement 7. Inventories, indices, summaries of does held by third-party vendor 8. Litigations, arbitrations with investors (pleadings, discovery, settlements, etc.) 9. Redemption requests by others I418703v1 EFTA00730566 10. Filings with SEC or other agencies Fund Documents 1. Reports and communications with investors and FTC 2. Valuations, both internal and provided to investors 3. Account statements 4. LPAs and amendments; drafts 5. Subscription does 6. Offering Memoranda 7. SEC filings or other agency filings 8. Communications, meetings with Dubin and/or Zwim re FTC's initial investment and subsequent investments FTC Redemption 1. All docs re FTC redemption requests 2. Emails, notes, memos, telephone records 3. Internal memos and discussions 4. Analyses of FTC requests 5. Communications with others, incl. Glenn Dubin Other 1. List of all does withheld as privileged 2. Does concerning Dubin withdrawal of funds under management - 2 - I418703v1 EFTA00730567