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ermed asset-backed securities ("ABS"). When mortgages are packaged together for securitization, they are referred to as Mortgage Backed Securities ("MBS"), and when the mortgages are residential, those securities are referred to as Residential Mortgage Backed Securities ("RMBS"). 41. RMBS are, in
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
light of the Company's decision to use valuation and risk models that did not reflect the impact of the housing crisis on its most important assets: MBS. 89 EFTA00316817 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 105 of 347 368. As set out in the 2008 OIG Report, TM concluded that
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
he traders who were responsible for taking on additional risk. Bear Steams did not have risk managers that had experience or were capable of valuing MBS which were central to Bear Stearns' business models. (iii) Compliance With Rankine Regulations 731. In its third quarter 2007 Form 10-Q Bear Ste
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 Mohammed bin Salman and Molinaro

Jeffrey Epstein
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Bear Stearns
ORGANIZATION
JPMorgan Chase
ORGANIZATION
Goldman Sachs
ORGANIZATIONSchwartz
PERSON
Adam Sandler
PERSONAce Greenberg
PERSON
Jimmy Cayne
PERSONFarber
PERSON
Credit Suisse
ORGANIZATION
Spector
PERSONRabobank Group
ORGANIZATIONStandard & Poor's
ORGANIZATIONthe Executive Committee
ORGANIZATIONCo-Chief
ORGANIZATIONthe High Grade Hedge Fund
ORGANIZATIONRestricted Stock Plan Units
ORGANIZATIOND&L AAG
ORGANIZATION