Epstein Secrets

s reports on internal control over financial reporting, required by Rule 302 of the Sarbanes-Oxley Act, were materially false and misleading because Bear Stearns' internal controls were ineffective. The Officer Defendants' statements were false and misleading because Bear Stearns' internal controls were signif

the losses on the remaining $845 million exposure were ultimately recorded, or if those losses were in fact ever recognized prior to its collapse. b. Bear Stearns' Financial Statements Misrepresented its Exposure to Decline in the Value of RIs 389. Statement of Financial Accounting Standards No. 140, Accounti

and 10-K. 124 EFTA00316852 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 140 of 347 501. The quarterly and annual reports signed by Farber repeatedly touted the Company's risk management, including its use of internally-developed models to derive the fair value of the Company's financi

mpliance Inspections and Examinations ("OCIE") 117 EFTA00316845 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 133 of 347 to Defendant Farber, who reported directly to Molinaro. The disclosure controls and procedures that Molinaro purportedly put in place should have informed him that the

' Leveraging Practices 19 3. Bear Stearns' Backing of the Hedge Funds 20 E. Bear Stearns' Misleading Models and Inadequate Risk Management 23 I. Bear Stearns' Misleading Valuation and Risk Models 23 a. The Importance of Valuation Models 24 EFTA00316715 Case 1:08-cv-02793-RWS Document 102 Filed 02/27

to applicable clients and firm professionals. The ARAs are included in the AICPA's annual Audit and Accounting Manual ("AAM"). 345. In particular, Farber, Bear Steams' Senior Vice President-Finance and Controller, had previously been a partner with Deloitte. Accordingly, Farber should have had familia

Defendants) 214 COUNT III For Violations of Section 20A of the Exchange Act (Against Defendants Cayne, Schwartz, Spector, Molinaro, Greenberg, and Farber) 215 vi EFTA00316720 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 8 of 347 PRAYER FOR RELIEF 116 DEMAND FOR JURY TRIAL 218 vii

palcpaion prorman and real estate animal dug fawns) and Ordrisred podia% re ire* briar Inn Crean =cured «cans hare not been registered wih the Sterns and ExchangeComma:A a tender any state nines laws We provide nava vain fa pone nestrant sedates and sauchen froduas for Mona« purposes only ACO-ta

agent senses that we provide to Be mho' funds These fees greatly are paid from nano assets n the mrtual fund and real/ad dollar moist based on the Farber of accounts at the broker-dealer holding mutun funis of that fund arraly. CONFIDENTIAL — h addax to comernsom reread in <ornerier wth the sate a