Epstein Secrets

76 MOTION to Dismiss the Verified Third Amended Shareholder Derivative and Class Complaint. Document filed by Samuel L. Molinaro, Jr, Henry Bienen, James E. Cayne, Jeffrey M. Farber, Carl D. Glickman, Michael Goldstein, Alan C. Greenberg, Donald J. Harrington, JP Morgan Chase & Co., Jeffrey Mayer, Michael Min

t Samuel L. Molinaro, Jr, Henry Bienen, James E. Cayne, Jeffrey M. Farber, Carl D. Glickman, Michael Gol

oned litigation. We write pursuant to Your Honor's Individual Practice 2.0 to request permission to exceed the page limit set therein. Specifically, Deloitte respectfully requests permission to file a reply memorandum of no more than thirty (30) pages. ENDORSEMENT: So Ordered. (Signed by Judge Robert W.

internal control structure and procedures of the issuer for financial reporting. 357. In connection 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

olders' equity was 18.3%. "We are pleased with this excellent performance, revenues for the first quarter were up for every business segment," said James E. Cayne, chairman and chief executive officer of The Bear Steams Companies Inc. "Growing the company remains a core focus as we 164 EFTA00316892 Case 1:

ms provided no further public disclosure about the losses it incurred related to its loans to the hedge funds. 381. As more fully set forth below, Deloitte knew or should have known of an additional auditing red flag in the Company's related party transactions. 382. The primary literature for related

mark disputes; and (iii) falsely inflating its net capital by using misleading methods to calculate VaR. (iv) Internal Controls 732. Defendants Cayne and Molinaro each made false and misleading statements when they executed Sarbanes Oxley Act certifications, annexed as an exhibit to the Form 10-Q

aking losses only by relying on misleading valuation models that failed to reflect the declining value of its highly illiquid Level 3 assets. (v) Deloitte's Certification 735. As an auditor Deloitte also certified Bear Steams' third quarter 2006 Form 10-Q, as required by Sarbanes-Oxley, and, in so do