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rest, exceed $45 million. Introduction 2. At all times relevant to the claims stated herein, Claimant FTC was a corporation owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful investor. At all times relevant to the claims stated herein, Claimant COUQ was a private foundation managed by
million. Introduction 2. At all times relevant to the claims stated herein, Claimant FTC was a corporation owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful investor. At all times relevant to the claims stated herein, Claimant COUQ was a private foundation managed by Epstein.
imant FTC was a corporation owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful inv
ld by both the High-Grade and Enhanced Funds. Had Mr. Epstein been made aware of the true nature of what was t
convinced Epstein to move FTC's investments from the High-Grade Fund into the Enhanced Fund. Respondent Spector, who at the time was President and Co-Chief Operating Officer of Bear Steams, personally solicited FTC, through Epstein, to invest in the Enhanced Fund, providing clearly misleading and false
agement. 4. Mr. Spector's responsibilities included providing investment advice to certain valuable Bear Stearns clients. One of those clients was Jeffrey Epstein. Mr. Epstein was a former Bear Steams partner and subsequently became a successful investor who invested substantial sums based on advice given by
ctor's responsibilities included providing investment advice to certain valuable Bear Stearns clients. One of those clients was Jeffrey Epstein. Mr. Epstein was a former Bear Steams partner and subsequently became a successful investor who invested substantial sums based on advice given by Bear Steams.
e Bear Stearns clients. One of those clients was Jeffrey Epstein. Mr. Epstein was a former Bear Steams pa
lients. One of those clients was Jeffrey Epstein. Mr. Epstein was a former Bear Steams partner and subsequentl
e Chief Executive Officer of The Bear Steams Companies. I also was Chairman of the Board from 2001 to 2008. 3. Warren Spector was Co-President and Co-Chief Operating Officers of The Bear Steams Companies from 2001 until August 2007. Mr. Spector was responsible for overseeing the hedge fund business of
create the fiction that he was not involved. 5. In the 1990s, at a time when I trusted Warren, I introduced him to my friend and former colleague Jeffrey Epstein. I introduced him as someone Jeffrey could trust. I now regret both the trust I put in Warren and my introduction of him to Jeffrey. 6. Over time
5. In the 1990s, at a time when I trusted Warren, I introduced him to my friend and former colleague Jeffrey Epstein. I introduced him as someone Jeffrey could trust. I now regret both the trust I put in Warren and my introduction of him to Jeffrey. 6. Over time I observed that Jeffery relied upon W
rey became friends. EFTA00725242 7. Warren was not worthy of the trust that Jeffrey placed in him. [DOES JC HAVE KNOWLEDGE OF WARREN SEEKING OUT JE FOR THE FUNDS? IF SO, WE SHOULD AMPLIFY HERE] 8. It is now apparent that the Funds were not properly managed from the outset. It is also clear th
ed him to my friend and former colleague Jeffrey Epstein. I introduced him as someone Jeffrey could trust.
Executive Officer on January 8, 2008, but remained with Bear Stearns as the non-executive chairman through 2. Warren Spector was Co-President and Co-Chief Operating Officer of Bear Stearns from June 2001 to August 2007. Warren was forced to resign from those positions on August 5, 2007, but remained e
in connection therewith, makes investments in securities and other investments, which it reasonably expects to be profitable and appropriate. 6. Jeffrey Epstein ("Epstein"), a Virgin Islands resident, was at all relevant times herein the president, a director, and the sole shareholder of Financial Trust. Ep
rewith, makes investments in securities and other investments, which it reasonably expects to be profitable and appropriate. 6. Jeffrey Epstein ("Epstein"), a Virgin Islands resident, was at all relevant times herein the president, a director, and the sole shareholder of Financial Trust. Epstein has
y expects to be profitable and appropriate. 6. Jeffrey Epstein ("Epstein"), a Virgin Islands resident, w
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
Livney Thomas Marano Other Officers Samuel L. Molinaro Jr.""' Executive Vice President and Chief Financial Officer Kenneth L. Edow Secretary Jeffrey M. Father Senior Vice President—Finance and Controller Michael Minikes Treasurer Michael S. Solender General Counsel Jeffrey Maya" Steven D. Mey
ef Financial Officer Kenneth L. Edow Secretary Jeffrey M. Father Senior Vice President—Finance and Con
ayno Chartism of the Board and Chief Executive Officer Alan C. Greenberg" Chairmen of the Executive Committee Alan D. Schwartz""' President and Co-Chief Operating Officer Warren J. Specter'"' President and Co•Ctief Operating Officer Henry S. Biener" Resident, Northwestern University Carl D. adama
C. Greenberg 121 F. Michael J. Alix 123 G. Jeffrey M. Farber 124 H. Corporate Scienter 125 iii
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
ocess, the SEC told Principal Accounting Officer Jeffrey Farber — Molinaro's direct report — that "Is* bel
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
Entities connected to both Jeffrey Epstein and Co-Chief
Leon Black
PERSON
Alan Dershowitz
PERSON
JPMorgan Chase
ORGANIZATION
Bear Stearns
ORGANIZATIONthe State of New York
LOCATIONAce Greenberg
PERSON
Jimmy Cayne
PERSON
Credit Suisse
ORGANIZATION
Mohammed bin Salman
PERSON
Goldman Sachs
ORGANIZATION
the Board of Directors
ORGANIZATION
Adam Sandler
PERSONStandard & Poor's
ORGANIZATIONSchwartz
PERSON
Spector
PERSONthe Executive Committee
ORGANIZATIONBear, Steams & Co. Inc.
ORGANIZATION
Ralph Cioffi
PERSONCioffi
ORGANIZATIONFarber
PERSON