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ation process. RSU: Restricted Stock Units. Sarbanes-Oxley Act: Sarbanes-Oxley Act of 2002. Schwartz: Defendant Alan D. Schwartz, Co-President and Co-Chief Operating Officer of Bear Stearns. He became sole President on August 5, 2007. Scratch and Dent Loans: Risky mortgages that were already in default
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
hen his resignation was announced, Bear Steams share price plunged nearly 7%. B. Alan D. Schwartz 464. As Chief Executive Officer, Co-President, Co-Chief Operating Officer, and director of Bear Steams, Defendant Schwartz participated in the issuance of, and signed and certified as accurate and comple
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
January 2008 and Chairman of the Board from 2001 until Bear Stearns' collapse in March, 2008. 10. Warren Spector ("Spector") was Co-President and Co-Chief Operating Officer of Bear Stearns from 2001 until August 2007. Spector was forced to resign these EFTA00729584 Case: 3:09-cv-00106 Document #: 1
nstruments was $19.725 billion. 30. All of the SEC filings referred to herein which had been read and relied upon by Epstein had been certified by Molinaro as the CFO of Bear Stearns and, with the exception of the 200710-K, all of the SEC filings referred to herein had been certified by Cayne as the CE
Entities connected to both Co-Chief and Molinaro

Jeffrey Epstein
PERSON
Spector
PERSONAce Greenberg
PERSON
Alan Dershowitz
PERSON
Bear Stearns
ORGANIZATION
Jimmy Cayne
PERSONSchwartz
PERSONthe Executive Committee
ORGANIZATIONFarber
PERSONAlan D. Schwartz
PERSON
Mohammed bin Salman
PERSON
JPMorgan Chase
ORGANIZATIONRabobank Group
ORGANIZATIONLeon Black
PERSON
Credit Suisse
ORGANIZATIONAuditing Standard
ORGANIZATIONthe High Grade Hedge Fund
ORGANIZATIOND&L AAG
ORGANIZATIONServicing of Financial Assets and Extinguishment of Liabilities
ORGANIZATIONModel Review
ORGANIZATION