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ure had the desired effect, as analysts covering the Company took note of its remarkably low VaR numbers. In a February 9, 2007 pre- filing comment, Credit Suisse analysts Susan Roth Katzke and Ross Seiden stated that Bear Steams' "[m]anagement will continue to invest to grow revenues via new products and new
ear Steams. On August 5, 2007, he was also appointed COO. During the Class Period, when the price of Bear Steams' shares was artificially inflated, Molinaro sold 38,552 shares for a total realized value of $4,230,828. 28. Defendant Michael Alix ("Alix") was the Senior Managing Director and Global Head
sks" but that TM documents did not reflect "how the Company dealt with default risks." 106. Defendant Cayne, the CEO of the Company, and defendant Molinaro, the CFO of the Company, were aware of the SEC's concerns about Bear Steams risk management program. According to a February 8, 2008 presentation b
ccordance with generally accepted accounting principles[.] 474. Moreover, according to a February, 2008 presentation given by Molinaro himself to Credit Suisse analysts, the Company's risk management structure reported directly to him. 475. As alleged above in paragraphs 106,167 and 175, Molinaro knew, or
tion with the Company's 2006 Form 10-K, Defendants Cayne and Molinaro executed the applicable Rule 302 certification. 358. Defendants Schwartz and Molinaro filed identical certifications with respect to the Company's 2007 Form 10-K. 359. As explained above and in the Company's regulatory filings, in d
2006 Earnines Conference Call 598. On December 14, 2006, Bear Steams held its fourth quarter 2006 earnings conference call, conducted by defendant Molinaro, the Company's CFO. During the call, Molinaro repeated the financial results set out in paragraphs 590 above. These statements were false and misle
mpany's total assets held at market value, or a total of about $24.41 billion. Moreover, according to the Company's February 8, 2008 presentation to Credit Suisse analysts, $7.5 billion of this amount represented residential mortgages. Because these assets were highly leveraged, even a small decline in value
aterial respects the financial condition." 188 EFTA00316916 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 204 of 347 733. Cayne and Molinaro also certified that the Company had: resigned such internal control over financial reporting, or caused such internal control over financial report
tements and certifications were materially false and misleading when made. 5. November 14, 2007 Write Downs 736. On November 14, 2007, Defendant Molinaro announced that Bear Stearns would write down $1.2 billion of its assets in the fourth quarter. However, Molinaro misleadingly attempted to reassure
Entities connected to both Credit Suisse and Molinaro

Jeffrey Epstein
PERSONLeon Black
PERSON
Bear Stearns
ORGANIZATION
JPMorgan Chase
ORGANIZATION
Goldman Sachs
ORGANIZATION
Alan Dershowitz
PERSONAce Greenberg
PERSONSchwartz
PERSONthe Executive Committee
ORGANIZATION
Jimmy Cayne
PERSON
Spector
PERSON
Mohammed bin Salman
PERSONFarber
PERSON
Adam Sandler
PERSON
Exchange
ORGANIZATIONStandard & Poor's
ORGANIZATIONRabobank Group
ORGANIZATION
Basel II
ORGANIZATION
Deloitte
ORGANIZATIONCo-Chief
ORGANIZATION