Epstein Secrets

T OF TIME Civil No. 2009-106 Page 2 capital reserves, and the quality of its risk management in order to induce plaintiff to retain its shares of Bear Steams stock. 3. On December 3, 2009, counsel for defendant filed with the Judicial Panel on Multi-District Litigation (the "MDL Panel") a Rule 7.5 Notic

counsel. 4. In August 2008, the MDL Panel joined for consolidated or coordinated pretrial purposes fifteen actions (the "Related Actions") against Bear Stearns concerning "whether Bear Stearns and certain of its current and former officers and directors knowingly made material misstatements or omissions co

INC. ) ) Defendant. ) ) DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME TO ANSWER, MOVE, OR OTHERWISE RESPOND TO THE VERIFIED COMPLAINT Defendant The Bear Stearns Companies Inc. ("Bear Stearns" or "defendant"), hereby respectfully moves, under Fed. R. Civ. P. 6(b), for an enlargement of time within which to answer, move, or

2009 Page 13 of 19 Financial Trust Company, Inc. vs. The Bear Stearns Companies Inc. Verified Complaint Page 13 quoting Schwartz as stating that Bear Stearns' 'balance sheet, liquidity, and capital remain strong". 51. On or about the weekend of March 14, 2008, J1' Morgan offered just $2.00 a share for Bea

intiff, Financial Trust Company, Inc. ("Financial Trust"), by and through its undersigned counsel, and for its Verified Complaint against Defendant The Bear Stearns Companies Inc. ("Bear Stearns"), alleges as follows: 1. Financial Trust was at all relevant times herein a corporation incorporated under the laws of the Virgin

shorter grace period for a covenant breach than provided above. Certain series of debt securities that we assumed in connection with our merger with Bear Steams include additional events of default as well. Accordingly. new series of senior debt securities offered by use of this prospectus will not have the

provided above. Certain series of debt securities that we assumed in connection with our merger with The Bear Steams Companies LW (formerly known as The Bear Stearns Companies Inc.). which we refer to as " Bear Steams? include additional events of default as well. Accordingly. the senior debt securities offered by use of this p